COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX)-1, NEW DELHI vs. DENSO INTERNATIONAL ASIA CO. LTD.

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ITA/189/2025HC DelhiDLHC01119697202406 November 2025Bench: HON'BLE MR. JUSTICE V. KAMESWAR RAO,HON'BLE MR. JUSTICE VINOD KUMAR1 pages
AI SummaryWithdrawn

What did the High Court hold?

The High Court dismissed the appeal as withdrawn. This decision was based on the computation sheet filed by the respondent's counsel, which showed the net tax effect to be Rs. 1,81,31,975/-. The appellant's counsel did not contest this figure. The court's reasoning implicitly relies on a policy or guideline where appeals with a tax effect below a certain threshold (in this case, Rs. 2 crores, as indicated by the figure) are to be withdrawn. Therefore, the appeal was not decided on its merits but was disposed of as withdrawn due to the low tax effect.

What were the facts?

The appeal, ITA 189/2025, was filed by the Commissioner of Income Tax (International Tax)-1, New Delhi, against Denso International Asia Co. Ltd. The appeal was before the High Court of Delhi. The core of the matter revolved around a computation sheet filed by the respondent's counsel, Mr. Vishal Kalra, which indicated a net tax effect of Rs. 1,81,31,975/-. This figure was not contested by the appellant's counsel, Mr. Puneet Rai. The procedural history leading to this point is not detailed in the provided text.

What were the issues?

The High Court was to decide whether to proceed with the appeal. The primary issue, as presented by the court's action, was the tax effect of the matter. The appellant, represented by Mr. Puneet Rai, did not contest the tax effect as computed by the respondent. The respondent, represented by Mr. Vishal Kalra, submitted a computation sheet showing a net tax effect of Rs. 1,81,31,975/-. The court's decision hinges on this figure being below a certain threshold, which is implied to be the reason for dismissal as withdrawn. No specific provisions of the Income Tax Act were explicitly debated in the provided text.

AI-generated summary — verify with the full judgment below

$~3 * IN THE HIGH COURT OF DELHI AT NEW DELHI + ITA 189/2025 COMMISSIONER OF INCOME TAX (INTERNATIONAL TAX)-1, NEW DELHI .....Appellant Through: Mr. Puneet Rai, SSC, Mr. Gibran, JSC, Mr. Ashvini Kumar and Mr. Rishabh Nangia, Advs. versus DENSO INTERNATIONAL ASIA CO. LTD. .....Respondent Through: Mr. Vishal Kalra, Mr. Ankit Kumar and Mr. Anil Kumar, Advs. CORAM: HON'BLE MR. JUSTICE V. KAMESWAR RAO HON'BLE MR. JUSTICE VINOD KUMAR O R D E R %

06.11.2025 In view of the computation sheet filed by Mr. Vishal Kalra, Advocate, showing the net “Tax Effect” as Rs1,81,31,975/- which is less than Rs.2 crores, which aspect is not contested by Mr. Puneet Rai, SSC, the appeal is dismissed as withdrawn. V. KAMESWAR RAO, J VINOD KUMAR, J NOVEMBER 06, 2025 dd This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 11/11/2025 at 15:03:47

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